Last week it was reported that the search giant Google legally avoided $2 billion in income taxes worldwide by shifting $9.8 billion into a shell company in Bermuda, which has no corporate income tax.

But if you’re looking for the deal those big guys got, you can just forget it, thanks to FATCA — like fat cat, except you leave off the last “t” for “Tough luck, pal.”

FATCA, or the Foreign Account Tax Compliance Act, which takes effect Jan. 1, has the ostensible aim of cracking down on overseas tax havens. FATCA requires foreign banks to report US account holders to the IRS or face financial penalties.

But as in the case of Google, multinationals have resources to adapt to the law that individuals living overseas can’t hope to match.

Anecdotal evidence suggests that FATCA is already making financial life difficult for overseas Americans, over and above the possible tax bite. Some smaller banks are rejecting new and canceling old expatriate accounts, rather than spend the money to comply with the law. Mortgages are reportedly being denied or called in.

“Recent research suggests that the costs for each typical non-US bank to become FATCA-compliant could run to tens of millions of dollars,” says Nigel Green, chief executive of international consultancy deVere Group, which caters to expatriate clients.

“FATCA will dramatically reduce foreign investment in the US at a time when the economy is teetering on a knife edge,” predicts Green. “All this for the purpose of recovering $1 billion per year, which observers . . . say is only just enough to run the federal government for around two hours.”

Green says a number of his clients are considering giving up their US citizenship.

“Let’s say you’ve gone overseas and settled down and met a young lady, so perhaps you’re not going back to America,” he says. “It’s a nice passport,” he says many clients tell him. “But it’s not worth the trouble.”